United Healthcare Corp. v. American Trade Insurance Company, Ltd., 88 F.3d 563 (8'h Cir. 1996); Granite State Outdoor Advertising, Inc. v. City of Cleanvater, Fla., 351 F.3d 1112 (11th Cir. 2003) (a party may assert only his or her own rights and cannot raise the claim of third parties not before the cour